CHEMICAL MANAGEMENT RESOURCE GUIDE FOR SCHOOL ADMINISTRATORS doc

• Establish a leadership team consisting of qualified and experienced individuals to oversee chemical management activities and confirm the availability of budget and resources Section I

United States Environmental Protection Agency

Office of Pollution Prevention and Toxics

Washington, DC 20460

EPA 747-R-06-002 December 2006

Acknowledgements

The time and effort that many individuals contributed to the review and development of this

document is gratefully acknowledged by the U.S Environmental Protection Agency (EPA) This

document was prepared by Battelle Memorial Institute under contract EP-W-04-021 at the

direction of Mr Clarence Lewis of the EPA Office of Pollution Prevention and Toxics

Disclaimer

This document was prepared under contract to an agency of the United States Government

Neither the United States Government nor any of their employees makes any warranty, expressed

or implied, or assumes any legal liability for any third party’s use of or the results of such use of any

information, product, or process discussed in this document Mention or illustration of company

or trade names, or of commercial products does not constitute endorsement by the EPA As of

the date of this document, external links are current and accurate, and are offered by way of

example only for reference purposes The EPA is not responsible for content of non-EPA links

Summary

“…No one was sure what chemicals were involved in the fire [in the facilities maintenance warehouse at the

school] Pallets of bleach, ammonia and sulfuric acid based drain cleaner had been stored adjacent to each other,

and rupturing of the chemicals during the fire created an acid vapor cloud as well as chlorine and phosgene gases

The total cost of this event was about half a million dollars.”

– From a case study of a suburban public high school in New England1

Are there Dangerous Chemicals in Your School?

The sources of dangerous chemicals in schools are not always obvious This guidance applies to any

school that purchases, uses, stores, or

disposes of chemicals or products containing

dangerous materials Some of the most

common dangerous chemical products in

schools include:

• Laboratory chemicals (e.g., acids, bases,

solvents, metals, salts)

• Industrial arts or “shop” classes (e.g., inks,

degreasers)

• Art supplies (e.g., paints, photographic

chemicals)

• Pesticides, fertilizers, and de-icers

• Maintenance supplies and equipment

(e.g., drain cleaners, floor stripping

products, paints, oils, boiler cleaners, fuels,

mercury switches and gauges)

• Health care equipment (e.g., mercury

thermometers)

Who Should Read This Guidance?

This document is designed primarily for school administrators (principals and other policymakers), but may also be of value for

teachers, maintenance personnel,

superintendents, school business officials,

insurance industry risk managers, and

parents

What Can Schools

Do to Prevent Spills and Costly Incidents

of Dangerous Chemicals?

• Establish a leadership team consisting of qualified and experienced individuals to oversee chemical management activities and confirm the availability of budget and resources (Section III.A)

• Implement pollution prevention and green chemistry (safer alternatives) principles, whenever possible, to minimize the use

of hazardous chemicals at schools (Section III.B)

• Establish a chemical management policy and chemical hygiene plan (Section III.C)

• Conduct periodic chemical inventories to identify hazards (Section III.D)

• Establish an environmentally preferable purchasing policy (Section III.E)

• Implement an appropriate chemical storage and handling policy (Section III.F)

• Establish a training program for hazardous chemicals management and safety

(Section III.G)

• Develop a hazard communication plan to foster awareness among school personnel and students about the range of chemicals and products used in schools

(Section III.H)

• Create an emergency response and spill clean-up plan and ensure that all chemicals are disposed of in accordance with federal, state, and local regulations (Section III.I)

EPA Resources for Additional Information

• EPA, Healthy School Environments, http://www.epa.gov/schools/

• EPA’s Schools Chemical Cleanout Campaign (SC3), http://www.epa.gov/sc3/

• EPA, Where You Live, http://www.epa.gov/epahome/whereyoulive.htm

What Legal Requirements Do I Have?

Some chemicals purchased by schools may need to be managed as hazardous wastes and may

ultimately require disposal as such Hazardous wastes need to be managed from their initial point of

generation until their ultimate point of disposal, known as “cradle to grave.” The Resource Conservation

and Recovery Act (RCRA) gives EPA the authority to control the generation, transportation, treatment,

storage, and disposal of hazardous waste Any school that generates hazardous wastes must notify their

state environmental agency and obtain an EPA Identification (ID) Number This EPA ID Number must be

put on all manifests for tracking disposal of school wastes and must be site specific for the address given

School liability does not end when the wastes leave the school, and school administrators must make sure

they receive a copy of the shipping manifest stating that their wastes arrived at their destination (e.g.,

treatment, storage, or disposal facility) Laws and regulations pertaining to RCRA are available at

http://www.epa.gov/epaoswer/osw/laws-reg.htm

EPA’s Healthy School Environments Assessment Tool (HealthySEAT) provides information to help

determine if a school is subject to Federal OSHA requirements at

http://www.epa.gov/schools/healthyseat/frequentquestions.htm Although Federal OSHA does not have

jurisdiction over state and local government employees, including those in public schools, the 26 states

that operate OSHA-approved State Plans are required to extend their state standards to these workers

A list of OSHA State-Plan states is located at

http://www.cdc.gov/niosh/docs/2004-101/appena.html#oshasps Each state’s programs are unique and may have additional regulations and

requirements In states under Federal OSHA without State Plans, OSHA has no authority to inspect or

enforce standards in public schools; however, the local Federal OSHA office may be able to provide

hazard recognition assistance and technical support Compliance assistance information is available

on OSHA’s website at http://www.osha.gov

The National Institute for Occupational Safety and Health (NIOSH) provides a comprehensive safety

checklist program for schools at http://www.cdc.gov/niosh/docs/2004-101/default.html, which contains

recommendations and detailed checklists on OSHA regulations, along with background information on

how to make sense of regulations that may be applicable to schools (http://www.cdc.gov/niosh/docs/

2004-101/chap1.html)

In addition, EPA may enforce certain OSHA standards, such as Hazardous Waste Operations

(29 CFR 1910.120) or relevant EPA standards in public schools In addition to Federal

requirements, states may have their own laws Legal requirements are often updated and vary

from state to state In many states, the health and safety of public employees, including teachers

and other school staff, fall under the jurisdiction of a state agency, such as the state department

of labor or commerce

Check It Out

Note:

This document is intended

to serve as guidance only and does not supersede any federal, state, or local laws and regulations

Where Can I Get

Additional Help?

Each EPA Regional Office shares common

chemical management goals; each region has

its own contact point to best serve schools in

their respective states For more information

on EPA programs for schools, such as EPA’s

Schools Chemical Cleanout Campaign (SC3),

legal requirements that schools may face, and

where your school can receive additional

help, refer to the following regional contact

information and websites in the box below

Local government entities that may be able

to help your school understand and address chemical management issues (e.g., treatment and disposal options) include Local

Emergency Planning Committees (LEPCs), local health departments, state environmental departments, and fire departments

For more information about how local organizations can help, visit EPA’s SC3 - Businesses and Community Organizations website at http://www.epa.gov/sc3/

Table of Contents

Page

Summary ii

I Overview 1

I.A Introduction 1

I.B Organization of this Guide 2

I.C Why You Should Be Concerned 3

II Hazardous Chemicals and Products in Schools 4

II.A Chemicals and Products of Concern 4

II.B Chemical Categories 4

II.C Where Chemicals and Products are Found 6

III Policies and Actions 8

III.A Leadership and Resources 8

III.B Pollution Prevention and Greener Alternatives 9

III.C Chemical and Product Management 11

III.D Chemical Inventory 12

III.E Purchasing 13

III.F Storage and Handling 15

III.G Training 16

III.H Hazard Communication 17

III.I Spills, Cleanup, and Disposal 17

IV Special Cases 20

IV.A Arsenic 20

IV.B Asbestos 20

IV.C Lead 21

IV.D Mercury 22

V Conclusion 24

References 25 Appendix A-1

Chemical Hygiene and Management Plans A-1 Sample Guidelines A-3 Checklists A-5 Chemical Purchasing, Storage, and Design Guidelines A-7 Use of Chemicals in Schools A-8

EPA has developed a unique software tool to help school districts evaluate and manage all of their environmental, safety, and health issues, including all aspects of their chemical management programs The Healthy School Environments Assessment Tool (HealthySEAT) can be customized and used, free of charge, by district- level staff to conduct voluntary self-assessments

of their facilities and to manage information on environmental conditions within each building

Source: EPA, HealthySEAT,

http://www.epa.gov/schools/

healthyseat/index.html

I Overview

I.A Introduction

From elementary school maintenance storage

closets to high school chemistry laboratories,

schools house a variety of chemicals Many

of these chemicals are hazardous and are

used daily; however, in some cases, these

chemicals have been unused for decades

Ensuring that these chemicals are managed

properly will help school administrators to:

safeguard the health and safety of students

and school employees; avoid disposal

expenses and costly school closures associated

with spills and emergency incidents; maintain

a sense of trust between the district and the

surrounding community; and prevent damage

to the environment School districts need

solid, useful, specific recommendations and

information on responsible chemical

management to facilitate the establishment of

sound district-level policies and procedures

This document is intended to aid K-12 public

school districts and private, religious, and

independent schools and school system

policymakers in reducing dangerous chemical

use and implementing responsible chemical

management practices Institutionalizing

such practices will help to minimize the

incidence of chemical spills, exposures, and

emergency scenarios in schools This

document focuses on broad policy

considerations that EPA recommends school

administrators consider implementing to

properly manage and use all dangerous

chemicals Parents and others in the

community interested in school health

and safety policies also may use this booklet

to determine whether their children’s schools

are effectively minimizing potential exposure

to dangerous chemicals and products

This document is part of EPA’s Healthy School Environments Initiative The Healthy School Environments website (http://www.epa.gov/schools/) serves as a gateway to on-line resources to help school administrators, teachers, facility managers and other staff, and parents address environmental health issues in schools

This document is also an integral part of the EPA Schools Chemical Cleanout Campaign (SC3) toolkit The goals of the SC3 are to: remove potentially harmful chemicals from schools; emphasize the implementation of preventive programs such as chemical management training for lab instructors and microscale techniques; and raise national awareness of the issue of chemicals in schools The ultimate goal of the SC3 is

to create a chemically safer school environment in which chemicals are purchased wisely, stored safely, handled by trained personnel, used responsibly, and disposed of properly Finally, this document includes numerous boxes highlighting information on relevant EPA and state information, such as the HealthySEAT tool developed by EPA as a resource to address chemical management among other environmental, safety, and health issues

I.B Organization of this Guide

Section I explains the need for responsible

chemical management policies and why

school administrators must be concerned

about chemical management in their schools

Section II provides an overview of the

various classes of hazardous chemicals and

products of concern found in schools, and

discusses where these chemicals and

products of concern might commonly be

found in schools

Section III presents recommendations for

school administrators to develop their own

consistent and effective policies, promotes

concepts such as pollution prevention and

green chemistry, and provides information

on best practices for the purchase,

identification, tracking, storage, use, and

disposal of hazardous chemicals found in

elementary and secondary schools

Section IV discusses special types of chemicals that are of particular concern

Section V presents conclusions

various “how to” forms, templates, and checklists for establishing policies and procedures that schools may use to facilitate the implementation of EPA’s recommendations

This document contains numerous references and endnotes to school-focused guidance documents and materials on chemical management, green chemistry, pollution prevention, environmentally preferable purchasing, and school cleanout campaigns initiated in school districts For example, the Los Angeles Unified School District, one of the largest school districts in the country, along with its home state of California, have been committed to spreading awareness about chemicals in schools, as illustrated below

The Los Angeles Unified School District (LAUSD) has been particularly active on issues related to chemicals in

schools The LAUSD’s Office of Environmental Health and Safety (OEHS) website contains a wealth of resources for school officials, including a searchable product review tool available on the OEHS Chemical Evaluation Program page ( http://www.lausd-oehs.org/productreview_chemeval.asp ) and comprehensive information about its Chemical Hygiene Program The OEHS Chemical Hygiene Program page ( http://www.lausd-oehs.org/chemical-hygiene.asp )

contains links to various handouts and the Science Safety Handbook for California Public Schools ( oehs.org/docs/Misc/CAScienceSafetyHandbook.pdf ) It also lists chemicals approved by the State of California and OEHS for use in LAUSD school laboratories These chemicals can be viewed by clicking the “View Approved Laboratory Chemicals” button on the OEHS Chemical Hygiene Program page (listed above)

http://www.lausd-The State of California has customized EPA’s HealthySEAT software to incorporate California’s regulations and

links to other state-specific information, including funding sources State-customized versions of HealthySEAT make

it easier for individual school systems to adapt and use the tool

There are five key reasons why school

administrators should be concerned about

chemical management in their schools:

Improper chemical management

poses health and safety risks to students

and school employees Health, learning,

and behavior risks to students are

of particular concern, as children are

more vulnerable than adults to chemical

exposures because their bodily systems are

still developing; they eat more, drink more,

and breathe more in proportion to their

body size; and their behavior can expose

them more to chemicals than adults

The expenses incurred from disposal,

spills, and other incidents, including

potential liabilities/lawsuits, can

be considerable The costs of

responding to chemical incidents can

reach hundreds of thousands of dollars or

more at a single school.2 In addition to

response costs, improper chemical waste

management can result in fines and

increased insurance premiums

It only takes one chemical incident,

such as a spill, explosion, or

chemical exposure, to break the trust

with the community Reported school

incidents can lead to increased parental and community concern, negative publicity, and embarrassment to the school and school district

Improper chemical management may result in school closures that

result in a loss of valuable education time

Improper chemical management can lead to unintended chemical discharges and spills, which inflict

damage upon the environment where

students, teachers, staff, and parents live and work Improper chemical discharges into sanitary sewer lines or on-site waste treatment systems (including septic tanks) can have adverse effects on rivers, streams, and groundwater Chemical releases and spills can also contribute to air pollution Spills to the ground can ultimately result

in long-term harm to the land and considerable remediation costs

A safe school environment that prevents harm to students and protects school employees from dangerous chemicals must

be promoted Responsible chemical management is likely to lead to improved learning in the classroom and improved overall health of the environment and the community

II Hazardous Chemicals and Products

in Schools

II.A Chemicals and Products

of Concern

Approximately 75,000 chemical substances

are in commercial use today.3 Many of these

chemical substances are considered toxic or

otherwise hazardous to humans and other

living beings Toxic chemicals are associated

with a variety of serious health problems,

including cancer, brain and nervous system

disorders, reproductive disorders, organ

damage, as well as asthma Toxic chemicals

that are persistent in the environment and

bioaccumulate through the food chain can

make exposure during childhood and

adolescence especially dangerous Chemicals

also can irritate the skin, eyes, nose, and

throat Some chemicals pose significant

safety hazards, such as fire or explosion risks

Many hazardous chemicals can be found in

school facilities Material Safety Data Sheets

(MSDS), comprehensive fact sheets prepared

by chemical manufacturers, describe the

physical properties, health effects, and

other characteristics of chemicals, as well as

procedures for handling, storing, and

disposing of these substances.4 Chemical

manufacturers should supply MSDSs along

with each shipment of chemicals delivered to

your school The proper use and

management of these substances, as well as

the products that contain them, are critical to

maintaining a healthy atmosphere for school

occupants and the surrounding environment

The term “hazardous chemicals” may include

(but is not limited to) the following:

• Laboratory chemicals used or stored in science laboratories and preparation areas;

• Art supplies, including paints, stains, inks, glazes, and photo processing chemicals, used in (visual and performing) art and shop;

• Cleaning products utilized by custodial, cafeteria, and maintenance staff;

• Pesticides, fertilizers, and de-icers/salts/ sands used for grounds maintenance,

as well as pesticides used for building maintenance;

• Paints, solvents, fuels, degreasers, and lubricants used in building operation and maintenance;

• Oils, fuels, paints, antifreeze, and other chemicals used to maintain and repair equipment for transportation, school maintenance, and shop classes;

• Inks, solvents, and adhesives used for printing in school offices; and

• Chemicals used to treat water associated with drinking water and swimming pools

II.B Chemical Categories

Chemicals can be grouped based on the type

of hazard they pose Understanding the different types of chemicals in a school is important for developing an effective chemical management policy Hazardous substances in schools may fall into one or more of the following categories:

flammables/explosives, corrosives (the majority of which in high school laboratories are acids and bases), oxidizers/reactives, toxics, and compressed gases Federal agencies and legislative authorities have developed specific definitions for each of those categories; however, the hazards can be described generally as follows:5

The risks associated with exposure to a

chemical are dependent on many factors, including

the chemical’s hazard level (degree of flammability,

toxicity, etc.), the route of exposure (e.g., absorbed

through skin, inhaled, consumed, injected), and the

duration of exposure

Chemical Type Description and Examples

Corrosives Chemicals that can burn, irritate, or destroy living tissue or corrode metal through direct

chemical action This category includes strong acids and bases (alkalines), as well as dehydrating agents and oxidants

Examples: sulfuric, nitric, and hydrochloric acids; potassium, ammonium, and sodium hydroxides (bases); hydrogen peroxide or chlorine (oxidants); acetic acid

Toxics Any substances that, even in small amounts, can injure living tissue when ingested,

inhaled, or absorbed into the skin

Examples: mercury; arsenic; lead; asbestos; cyanide

Compressed

Gases

Gases stored under high pressure such that cracks or damage to the tanks and valves used to control these gases could cause significant physical harm to those in the same room

Examples: acetylene; helium; nitrogen

Improper storage practices may increase the risks associated with certain chemicals, particularly those that are flammable, corrosive, or reactive The King County Laboratory Waste Management Guide (http://www.govlink.org/hazwaste/

publications/LabGuidelinesRevAugust06.pdf) provides suggestions for safe and effective chemical storage, including shelf storage patterns for small stockrooms (see Table 1)

EPA’s “No More ‘Methyl Something’: Improving Management of Curriculum Chemicals in Schools” presentation provides

examples of dangerous storage scenarios: http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/pdfs/chemsafe.pdf

Check It Out

II.C Where Chemicals and

Products are Found

Chemicals can be found throughout a school

They are used in both the maintenance of

schools and the curriculum taught

Chemicals help students to perform

experiments and learn new skills, among

other benefits In the absence of chemicals,

schools would lack certain fundamental tools

needed to educate students Despite their

useful purposes, chemicals can be dangerous

to students and staff when managed

improperly Hazardous chemicals are found

in classrooms, laboratories, storerooms,

maintenance sheds, and numerous other

areas High schools usually have larger

inventories and more hazardous chemicals

than middle and elementary schools

Chemicals may have been purchased by the

school or brought in by employees or

students for their personal use

The table on the following page lists some

specific locations in which chemicals and

products of concern might be found in a

typical school Please keep in mind that this

list is by no means all-inclusive, and that

chemicals, when used appropriately, can be

important to the educational process

Types and Locations of Hazardous Chemicals/Products in Schools:

• EPA, Chemical Management and Usage, http://www.epa.gov/Region7/education_resources/teachers/

ehsstudy/ehs1.htm and “No More ‘Methyl Something’: Improving Management of Curriculum Chemicals in Schools,” http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/pdfs/chemsafe.pdf

• Colorado Department of Public Health and Environment, One Hundred Most Commonly Found Explosive

and Shock-Sensitive Materials, www.cdphe.state.co.us/cp/Institutions/Schools/ChemsInSchools/

ExplosiveTop40.PDF

Alternatives to Products of Concern:

• EPA, Environmentally Preferable Purchasing, http://www.epa.gov/epp/Massachusetts Environmentally

Preferable Purchasing Program, Product and Service Information, http://www.mass.gov/epp/products.htm

• Maryland State Department of Education, Safety in Ordering, Storing, Using and Disposing of Chemicals,

Photo Credit: Rehab the Lab Program,

Local Hazardous Waste Management

King County, Washington

Location Product Type Hazardous Ingredient Examples

Concentrated Acids (undiluted) Hydrochloric acid Nitric acid

Science laboratories

Toxics

Cyanides Chromates (VI) Lead salts Mercury salts Solvents (used in paints, paint thinners, adhesives, lacquers,

primers, and other products) Petroleum naphtha Turpentine Cleaning supplies/detergents Phosphoric acid Sodium silicate

Vocational and

trade shops (can also be

referred to as Career and

Chromium

Visual and

performing art studios

Cleaning supplies/detergents 2-Butoxyethanol Trisodium phosphate Drain cleaners (alkaline)

Drain cleaners (acidic) Potassium hydroxide Sulfuric acid Pesticides (including disinfectants/sterilizers) Permethrin Sodium hypochlorite

Solvents (used in paints, paint thinners, adhesives, lacquers,

Nurses’ offices Medical equipment Mercury (thermometers and blood pressure manometers)

Intensifiers/reducers Potassium dichromate Hydrochloric acid

Photography laboratories

Stop baths and fixer Acetic acid Chrome alum (potassium

chromium sulfate) Pesticides 2,4-D

School grounds/

Correction fluid Ethylene glycol Trichloroethane Solvents (used in paints, inks, paint thinners, adhesives,

lacquers, primers, and other products) Methyl ethyl ketone Petroleum distillates

Administrative offices

Training and Teamwork Approach

to Safety and Chemical Hygiene

“Northshore School District, in Washington State,

has adopted the training and teamwork approach to

Safety and Chemical Hygiene in the past 2 years

As a result, last year our insurance pool lowered our

annual insurance premium by $30,000 for our efforts

In enacting these programs our Director of Curriculum,

Director of Risk Management, and the Chemical Hygiene

Officers saved money for the district.”

John Schmied, Northshore School District Chemical Hygiene Officer

III Policies and Actions

The following sections provide guidance on

recommended chemical management policies

These policies relate to: pollution prevention

and green chemistry (concepts that minimize

the potential for hazardous chemical use in the

first place); the general management of

chemicals and products already present in

schools; chemical inventories; the purchasing

and tracking of chemicals; the storage and

handling of hazardous chemicals; personnel

training and hazard communication; and

chemical spills, cleanup, and disposal To

properly implement these suggested policies,

schools should establish a leadership team and

confirm the availability of budget and

resources

III.A Leadership and

Resources

To institute good chemical management

policies, school administrators need to set the

tone that chemical management is important

by assigning roles and responsibilities for

implementing proper safety and chemical

hygiene practices Guidelines are provided

below that policymakers at the district level

and school administrators should implement

in order to initiate responsible chemical

management practices in their schools

• Establish or confirm that your district has committed budget and staff resources for chemical management

When schools consider their costs for chemicals, they generally consider only the purchase price Each stage of chemical and product management, however, has associated costs of labor (e.g., training chemical hygiene officer and other staff), materials, equipment, and disposal, as well

as costs of storage space and potential liability when responsible chemical management is not practiced

• Design and communicate a chemical management policy School district administrators and principals need to establish an overall policy stating a strong commitment to responsible chemical management, including implementation of the policies and actions defined in this document The policy should be communicated to all by the highest level of management Strong support from the administration, combined with adequate resources, will enable responsible chemical management Active involvement by the full school community is an important element of success, as well

• Appoint a chemical hygiene officer

The chemical hygiene officer is someone who is qualified by training and experience

to provide technical guidance and leadership in the development and implementation of the provisions of the chemical hygiene plan T he position description or job classification of a chemical hygiene officer will vary across school districts; however, in all cases, they should be trained to provide chemical management leadership to the school

• Designate a team to oversee the chemical management program at your school This team should consist of teachers, janitorial staff, and maintenance personnel to comply with the chemical hygiene plan and help oversee the chemical

management program at your school

described in the sections that follow

Team members should be trained by the

chemical hygiene officer (and reinforced

at least annually) At a minimum, team

members should understand physical/

chemical properties and potential

health effects of chemicals, chemical

compatibility, applicable environmental

regulations and compliance issues, and

waste management procedures of the

school You may also consider involving

students (as applicable) as part of the

process

• Disseminate information Share

experiences and lessons learned with other

school districts and administrators

Maintain a proactive program of informing

parents, guardians, teachers, and other staff

about chemical and product management

activities ongoing at your school

III.B Pollution Prevention and

Greener Alternatives

A key aspect of responsible chemical

management is identifying opportunities

to minimize chemical use through the

implementation of pollution prevention

and green chemistry principles

Pollution prevention (sometimes referred to

as “P2”) is defined as preventing or reducing pollution at the source, whenever feasible, and other practices that replace or eliminate the creation of pollutants An example of pollution prevention would be using smaller quantities of (or environmentally benign substitutes for) chemical products used for grounds maintenance or cleaning

A related concept, green chemistry, focuses

on science laboratories by reducing the levels

of toxicity and amount of chemicals used in experiments, promoting safety, pollution prevention, and waste minimization Similar concepts, microscale chemistry and small-scale chemistry, involve scaling down the quantities of chemicals required for science experiments resulting in improved laboratory safety Exploring and adopting pollution prevention and green chemistry concepts in

a school system results in many direct environmental benefits and often results in cost savings for schools

The following guidelines can be used to reduce or eliminate the generation of chemical pollutants and wastes

• Establish a policy that makes pollution prevention the preferred form of waste management and strives to eliminate the purchase and use of most, if not all, hazardous chemicals If elimination of the particular chemicals is not possible, other options include, in order of preference, reuse or recycling of chemicals and products; treatment of chemicals to reduce toxicity; and disposal of chemicals in an environmentally safe manner

While treatment may be a useful activity, it should be cautioned that the treatment of hazardous waste may require

a permit or be subject to regulation You should consider discussing any treatment options with state or local

regulatory agencies before you implement them in your laboratory Neutralization of acids and bases, permitted under federal law, is probably the most commonly used treatment method in educational institutions; however,

states may have more stringent standards regulating the disposal of acids and bases To learn more about

treatment methods, see Battelle Seattle Research Center’s “In-Laboratory Treatment of Wastes,” available on the P2 Pays website at http://www.p2pays.org/ref/01/text/00779/ch13.htm

Check It Out

The following resources provide technical background information to help schools implement their

own pollution prevention/waste minimization programs:

• Ohio EPA, Laboratory Pollution Prevention fact sheet, http://www.epa.state.oh.us/opp/Fact16_web.pdf

and P2 checklist of lab opportunities, http://www.epa.state.oh.us/ocapp/p2/labp2checklist.pdf

• Battelle Seattle Research Center, Laboratory Waste Minimization and Pollution Prevention: A Guide for

Teachers, http://www.p2pays.org/ref/01/00779.htm, and Chapter 8, Scaling Down Experiments,

http://www.p2pays.org/ref/01/text/00779/ch08.htm

• EPA, Pollution Prevention: Definitions, http://www.epa.gov/opptintr/p2home/p2policy/definitions.htm

• EPA, 12 Principles of Green Chemistry, http://www.epa.gov/greenchemistry/principles.html and Teachers, http://www.epa.gov/epaoswer/osw/conserve/clusters/schools/teachers.htm

• EPA, state P2 Programs, http://www.epa.gov/opptintr/p2home/resources/statep2.htm

• EPA, Integrated Pest Management (IPM) in Schools, http://www.epa.gov/pesticides/ipm/

• EPA’s Schools Chemical Cleanout Campaign (SC3), http://www.epa.gov/sc3/

• Great Lakes Regional Pollution Prevention Roundtable, Topic Hub™ for Pollution Prevention for Arts Education, http://www.glrppr.org/hubs/toc.cfm?hub=509&subsec=7&nav=7

• Green Cleaning Pollution Prevention Calculator, http://www.ofee.gov/janitor/index.asp

• Colorado State University, National Small-Scale Chemistry Center, http://www.smallscalechemistry.colostate.edu

• Merrimack College, National Microscale Chemistry Center, http://www.microscale.org/

• Contact your state pollution prevention

department for assistance in conducting

a pollution prevention opportunity

assessment, or contact your EPA Regional

Office at http://www.epa.gov/p2/pubs/

local.htm to find programs available in

your area as well as the issues affecting

your part of the country Each EPA

Regional Office supports pollution

prevention activities that reduce or

eliminate the sources of waste and

pollutants through work with voluntary

programs, partnerships with business

and industry, state and local governments,

citizens groups and other federal agencies

• Establish a pollution prevention program

to help your school minimize the amount

of chemical waste generated throughout

your school The program may consist of

developing school-wide and departmental

annual waste reduction goals The

program may also include pollution

prevention education sessions for teachers, maintenance staff, and students

emphasizing the importance of substituting hazardous chemicals with chemicals that are less hazardous and scaling down the volume of chemicals used in classroom experiments and maintenance applications

• Minimize the use of pesticides, a term that refers not only to insecticides but also to herbicides, fungicides, and various other substances used to control pests Children may be especially sensitive to the health risks posed by pesticides because their bodies are growing and developing; they may also have greater exposure to pesticides because of their increased hand-to-mouth behaviors A form of pollution prevention, integrated pest management (IPM), is an effective and environmentally sensitive approach to pest control that relies on common sense strategies to disrupt the life cycles of pests

EPA’s Schools Chemical Cleanout Campaign

Resources such as EPA’s SC3 program (see

http://www.epa.gov/sc3/) are designed to facilitate chemical

and product management The purpose of SC3 is to

reduce chemical exposures and improve chemical

management in K-12 schools By achieving these

environmental goals, the SC3 will contribute to the broader

goals of fewer lost schools days and healthier students,

faculty, and staff

In addition to EPA’s SC3, states have developed their own

SC3 programs:

• Florida Department of Environmental Protection, School

Chemical Cleanout Campaign (SC3),

http://www.dep.state.fl.us/waste/categories/hazardous/p

ages/schoolchemicals.htm; and

• Tennessee Department of Environment and

Conservation, School Lab Chemical Cleanout Campaign

(SC3), http://www.state.tn.us/environment/sc3/

III.C Chemical and Product

Management

Responsible chemical management is critical

to controlling a variety of environmental,

health, and safety issues within any school

Knowing what materials are present in your

school and how they are used, stored, and

discarded will enable you to understand the

issues associated with these substances

Properly recognizing and controlling the

hazards inherent to these materials, wherever

they are found in your schools, will enhance

your ability to create a safe school with

minimal environmental liabilities/lawsuits

Guidelines are provided below that

schools and administrators should implement

to initiate responsible chemical management

practices in their school

• Establish an environmentally preferable

chemical management policy considering

the entire chemical and product lifecycle,

which begins with chemical purchasing and

includes identification, labeling, storage,

inventory maintenance, and the activities

associated with the use and disposal of

chemicals and wastes generated from their

use, including training, spill control

procedures, and record-keeping

requirements

• Establish a district-level chemical purchasing policy, chemical products evaluation process, and a district-approved chemicals and products list (see Section III.E) For example, the Los Angeles Unified School District’s Chemical Hygiene Program (http://www.lausd-oehs.org/chemical-hygiene.asp) allows only approved chemicals to be used in school laboratories Controlling what chemicals are used within your schools is essential to ensuring that only products that have been reviewed and approved for use are brought into the school environment

• Create a written chemical hygiene plan that describes procedures and practices for the protection of students and school

employees from the health hazards presented by hazardous chemicals and products that are found in school laboratories The chemical hygiene plan is

a critical element of chemical management and should contain specific requirements and guidelines for chemical handling, inventory, storage, spills, and disposal The plan should be updated annually and whenever necessary The Appendix contains excerpts and references to several examples of chemical hygiene plans

Chemicals that are not correctly and clearly labeled, as shown in the photos above, should be disposed of properly Products used in schools should have an MSDS, be stored in their original containers, and be correctly and clearly labeled

Photo Credit: Rehab the Lab Program,

Local Hazardous Waste Management

King County, Washington

Chemical Inventory Safety Tips

The process of assessing existing chemical hazards can be

dangerous The following guidelines are recommended:

• Contact a trained professional to conduct a walk-through

inspection of the school to pre-screen for potential

hazards Certain types of chemicals pose an imminent

hazard (e.g., shock-sensitive materials) and must be

handled only by qualified emergency personnel or

hazardous waste professionals

• If the pre-screening establishes that it is safe to conduct

an inventory, ensure that the inventory team is properly

equipped with personal protective equipment and

emergency response supplies as well as chemical

management and safety knowledge

• Ensure that chemical storage areas are properly

ventilated and that potential sources of ignition are

turned off

• Conduct pre-screening, inventory and removal while

students are NOT in school

• When complete, provide your local fire department a

copy of the chemical inventory

Appendix 2 of the Massachusetts School Chemical

Management Program (available at http://www.mass.gov/

dep/service/schlchem.pdf) includes a step-by-step guide to

conducting chemical inventories

currently in use by school districts

nationwide

• Contact state or local health departments

or environmental agencies for more

information Many chemical management

practices are often regulated at the federal,

state, and/or local level

III.D Chemical Inventory

Existing accumulations of outdated,

unknown, poorly labeled, improperly stored,

degraded, and excessive quantities of

hazardous chemicals are present in many

schools These chemicals pose safety and

health risks to students and school personnel

Properly identifying and removing these

chemicals is a key step in preventing

accidents An important part of responsible

chemical management is the creation of an

accurate chemical inventory A chemical

inventory identifies the quantities and

physical locations of, as well as the potential

hazards associated with, all of the chemicals

used and stored in a school It also serves

as a reference for school and emergency personnel (e.g., local fire department) in the event of an emergency Furthermore,

a chemical inventory, when used to guide necessary purchases, can reduce the costs and management needs associated with excess chemicals

Guidelines are provided below that schools and administrators should follow in order to conduct an inventory at their school Some guidelines refer to other documents (e.g., chemical hygiene plans); information about these documents is discussed in later sections

• Conduct an inventory of all of the chemicals and products containing chemicals (e.g., mercury thermometers) stored on-site, covering all sections of the school including maintenance rooms and closets, storage sheds, greenhouses, and all

A chemical inventory identifies the amount and location

of all of the chemicals stored on-site, covering all sections of the school including maintenance areas

A thorough inventory would identify inappropriate chemical storage practices, such as the one shown in this photo Chemicals such as ammonia and bleach are commonly found in schools Despite their useful purposes, these chemicals are incompatible and should not be stored near each other, especially in maintenance storage areas or in hot boiler rooms where the bottles may bulge or break Mixing of these two chemicals would create a chlorine gas cloud

Photo Credit: Marina Brock, Barnstable County

(Massachusetts) Department of Health and

Environment

classrooms Engage all school staff who

will either be involved in conducting the

inventory, or will be having their chemicals

inventoried Pre-packaged science

experiments or demonstration kits should

be included in the chemical inventory

• Establish a policy that chemical inventories

be conducted and updated annually, unless

state or local regulations require a more

frequent schedule Contact your local state

agency, college or university, industry

partner, or chemical supplier, or identify

a responsible person within the school

who has training in hazardous chemical

management to assist with the inventory

• Review other documents you may have in

schools in your district, such as a chemical

hygiene plan or hazard communication plan, to

ensure that chemicals are consistently

being managed, stored, handled, and

disposed of properly Review your approved

chemicals and products list (see Section III.E)

Chemicals and products not on this list

should be removed and properly disposed

of or recycled according to applicable

federal, state, and local laws Update the

inventory when new chemicals or products

are added to the list and when chemicals or

products are used or disposed

• Conduct periodic cleanouts by identifying

and removing unnecessary hazardous

materials and expired chemicals through

appropriate recycling and/or disposal

methods Chemical inventories should be

conducted prior to cleaning out chemicals

from schools Contact your local state

agency, college or university, industry

partner, or chemical supplier, or someone

with technical qualifications to identify

potentially dangerous situations (i.e., school

staff should not move very old chemicals

because of the extreme hazard they may

present) and properly handle the chemicals

during a chemical cleanout

III.E Purchasing

Chemicals enter school systems through

a variety of avenues such as regular purchases (including purchase orders, purchasing cards, and personal purchases) by teachers and facility maintenance personnel, as well as donations from local industries and chemical

To create a chemically safer school environment, school administrators should implement measures to reduce the amount and hazardous nature of chemicals entering their schools Perform small-scale or microscale chemistry experiments or seek environmentally preferred products or services “that have a lesser or reduced effect

on human health and the environment when compared with competing products or services that serve the same purpose.”6

The following resources provide information to help schools conduct their own chemical inventories, including a suggested chemical inventory list You may also wish to check with your own state’s environmental and educational agencies

• Colorado Department of Public Health and Environment, Guidance on Chemical Management in Schools, http://www.cdphe.state.co.us/cp/Institutions/ Schools/ChemsInSchools/ChemMgmt.html

• Montana Department of Environmental Quality, Montana School Labs, http://www.mdeqschoollabs.com/

Check It Out

Environmentally Preferable Purchasing

EPA’s Environmentally Preferable Purchasing (EPP)

program was developed to assist federal agencies in

making environmentally conscious purchasing decisions;

however, businesses and state and local agencies have

also found the program to be of value The EPP website

(http://www.epa.gov/oppt/epp/pubs/about/faq.htm)

discusses frequently asked questions concerning EPP

and includes a number of tools and links to guidance

documents and case studies that schools can use to

identify products that are less hazardous

Here are some suggestions of best

management practices to create a

chemically safer school environment:

• Establish a purchasing policy that

addresses how chemicals and products

containing chemicals are entering a school,

who is using them, why they are being

used, and how they will need to be

disposed Involve all teachers,

maintenance and custodial personnel, and

other staff to ensure that the chemical

purchasing policy meets educational and

facility maintenance needs while reducing

the quantities and toxicity of chemicals

The Appendix provides resources to

chemical purchasing examples in schools

• Investigate pollution prevention and green

chemistry options (see Section III.B) to

determine whether certain chemicals can

be reduced in quantity or eliminated

entirely from science and art classes

• Establish an environmentally preferable

chemical screening process to ensure that

all chemicals and products containing

chemicals have been screened for

environmental, health, and safety hazards

prior to purchase, thus reducing and/or

eliminating hazardous chemicals

For example, the Maryland State

Department of Education provides

guidance on responsible chemical

purchasing.7 The MSDS may be useful

in this process

• Create an approved chemicals and products list, based on less toxic or non-toxic alternatives to make non-toxic implementation and enforcement easier

in your school Only allow procurement of approved chemicals

• Purchase chemicals and products containing chemicals in quantities that will

be used during the current school year or that can be fully consumed under normal conditions within the shelf life of the product Another concept is “just in time” purchasing in which chemicals are

purchased as needed throughout the school year These purchasing methods reduce the costs and management needs associated with excess and expired chemicals

• Use products purchased or approved by the school Teachers and other staff should be strongly discouraged from bringing in products on their own

Products used in schools should have

an MSDS, be stored in their original containers in a secure location, and be correctly and clearly labeled

Schools should exercise

EXTREME CAUTION when accepting chemical

donations, product samples, or promotional products (e.g., do not accept chemicals more useful for electroplating than for the teaching of high school chemistry) Schools should not give away chemicals

to avoid the costs of disposal

A few school districts have developed their own chemical hygiene plans that provide step-by-step procedures, as well

as checklists for the safe handling and storage of chemicals

• Northshore School District Chemical Hygiene Plan, http://schoolcenter.nsd.org/education/components/scrapb ook/default.php?cms_mode=view&sectiondetailid=58540

&sc_id=1161987494

• Lake Havasu Unified School District, Arizona District Chemical Hygiene Plan, http://www.havasu.k12 az.us/support/warehouse/chempolicy.html

• LAUSD, School Laboratory Chemical Hygiene and Safety Plan (Appendix F), http://www.lausd-oehs.org/docs/ CSC/Chemical%20Hygiene%20Plan.pdf

III.F Storage and Handling

School administrators should be aware

of proper use and storage policies

and procedures to ensure student and

employee safety Guidelines are provided

below that schools and administrators can

follow in order to reduce the risk of chemical

accidents and ensure that chemicals and

products in their schools are stored and

handled safely

• Establish a chemical storage and handling

policy that addresses how chemicals should

be properly stored, labeled, and secured, as

well as who should have access to these

chemicals and chemical storage locations

Chemicals should not be stored in areas

that are occupied by or accessible to

students, such as classrooms or restrooms;

they should preferably be stored in a

central, secure location The Appendix

provides resources to guidelines on the

proper labeling of chemicals,

recommended storage methods, and other

considerations for proper storage (e.g.,

examples of incompatible chemicals and

chemical segregation)

• Conduct at least annual inspections of

classrooms, janitorial closets, and chemical

storage rooms and cabinets in your school

to ensure the integrity of chemicals and

storage structures Spot inspections may

be performed periodically throughout the school year Engage maintenance staff in these inspections if storage shelving or locks are in need of updates or repair

Create and maintain an up-to-date map

of the location and storage pattern of chemical storage rooms and cabinets in your school

• Inspect and test emergency equipment (e.g., eyewash stations and safety showers)

as well as fume hoods and ventilation systems/exhaust fans at least on an annual basis.Engage maintenance staff in these inspections if safety equipment is in need

of updates or repair Establish protocols for the upkeep of emergency equipment and the associated maintenance records

• Work with a local chemical supplier to ensure you have MSDS information for all chemicals on site Hazardous chemicals in schools should be stored in accordance with MSDS specifications Maintaining

a hard copy or secure website access to MSDS information at the district level could be a cost-effective approach to ensuring that chemical safety information

is available across all schools At a minimum, MSDS information should be located in all chemical storage rooms and cabinets and in a central place within the school (away from the chemicals), as well

as a central location for the school district

To avoid a situation like the example shown above,

schools should establish a chemical storage and

handling policy that addresses how chemicals should

be properly stored, labeled, and secured, as well as

who should have access to them

Photo Credit: Rehab the Lab Program,

Local Hazardous Waste Management,

King County, Washington